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Finance Norway

Finans Norge

Finance Norway is the industry organisation for the financial industry in Norway.

Lobbying Activity

Meeting with Paulina Dejmek Hack (Cabinet of Commissioner Jessika Roswall) and Finanssiala ry - Finance Finland and

15 Jan 2026 · The link between insurance and the environment portfolio, resilience, simplification, the Single Market

Response to EU taxonomy - Review of the environmental delegated act

4 Dec 2025

Finance Norway is the business association for banks, non-life insurance and life insurance companies in Norway. See the attached file for the opinions of Finance Norway.
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Meeting with Katri Kulmuni (Member of the European Parliament) and Finanssiala ry - Finance Finland and

24 Sept 2025 · Nordic Finance evening -vastaanotto

Meeting with Antti Timonen (Cabinet of Executive Vice-President Henna Virkkunen), Marlene Rosemarie Madsen (Cabinet of Executive Vice-President Henna Virkkunen) and

24 Sept 2025 · Exchange about important digital policy priorities with representatives of Nordic Financial Associations

Meeting with Tomas Tobé (Member of the European Parliament) and Finanssiala ry - Finance Finland and

24 Sept 2025 · Finance Policy

Response to Delegated Regulation supplementing the review of prudential rules for the insurance and reinsurance sector (Solvency II)

5 Sept 2025

Finance Norway fully supports the response submitted by Insurance Europe and would like to use this opportunity to elaborate on one of the issues highlighted in the industry response which is of particular importance to the Norwegian insurance market; the calibration of interest rate risk for the Norwegian krone (NOK) under the standard formula. Finance Norway supports the overall framework of the new shifted methodology. However, to ensure fair competition across markets in line with the objectives of the EU's Savings and Investments Union, the methodology must be appropriately calibrated for all currencies to which it is applied. We therefore urge the Commission to allow for currency-specific calibrations of interest rate risk under the standard formula. For currencies like NOK, where monetary policy and market dynamics differ significantly from those of the Eurozone, a one-size-fits-all approach leads to distortions in capital requirements and does not reflect actual risk. A specific calibration for NOK should therefore be included in the delegated regulation. In the enclosed document, we show that the EUR-based calibration is overly conservative when applied to NOK and propose a NOK-based calibration which better reflects the actual behaviour of NOK interest rates. We thank the Commission for the opportunity to provide input and remain available for further dialogue. Yours sincerely Finance Norway Martin Carlén Chief Adviser
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Response to Recommendation on savings and investment accounts

2 Jul 2025

Finance Norway strongly supports the efforts to develop recommendations for the member states development of a savings and investment vehicle that facilitates retail investors access to investment opportunities. This enables retail ownership and engagement in increasing European competitiveness in line with the ambitions outlined for the Savings and Investment Union. To stimulate retail investors to enter the capital market and to take on more risk, accessibility, simplicity and accountability are essential factors. The investment opportunities need to be easy to find, and the investment process needs to be facilitated through channels that are familiar and reliable. Once the investment has been made, the retail investors obligations, like taxation and the potential execution of governance, needs to be digitalised and accessible, as well as stable over time. It is also important that the retail investor can access an overview of their investments and how they develop over time. It is important to make it easier for retail investors to access different types of equity investments. When households invest in equities, they become more involved in the economy's value creation. This helps them understand and see how value is shared in the economy. To allow each member state to successfully adapt an SIA to its national tax and pension system, the European Commissions blueprint should be grounded in the following three general principles, as presented in the Nordic financial sector input to a blueprint for savings and investment accounts: 1. Encouragement: Member states should be encouraged to introduce SIAs. 2. National design and implementation: The specific characteristics of the SIA, including taxation, should be designed and implemented at the member state level. 3. Best practices: Any specific features should be based on best practices, ensuring that no existing SIA becomes less favourable than it is today, as this would undermine the blueprints purpose.
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Response to Savings and Investments Union

7 Mar 2025

Further development of financial services and capital markets is essential for increasing the efficiency of the EU's internal market. Any EU initiatives should build on the national financial ecosystems that have developed over time and in tandem with the business they cater to. Finance Norway therefore believes policymakers should facilitated a bottom-up approach. Making best practices available and developing efficient infrastructure for the efficient dissemination of comparable material information is key. Norway is an integrated part of the internal market through the EEA Agreement. This integration is very important to Norwegian financial institutions. Participation in development towards enhancing European competitiveness is therefore central to Finance Norway and the Norwegian financial industry. The EEA Agreement The EEA Agreement ensures that Norway remains an integral part of the EU's internal market, allowing for seamless integration and cooperation in financial services. This integration is crucial for ensuring the supply of efficient, innovative and modern financial services in Norway, the Nordics and the internal market. Finance Norway is therefore concerned that all parties to the agreement continues their engagement and prioritisation of working with the agreement going forward. Increase in Equity Financing Material information for analysing risk characteristics and risk-rewards is necessary to make informed investment decisions. So is knowledge of the relevant tax environment. The ESAP is an important infrastructure for efficient dissemination of material information. The Commissions simplification agenda rightly addresses the need to streamline the information going into this. In addition to eliminating double reporting, lack of alignment in definitions and simplifying reporting operations, Finance Norway is eager to participate in the discussion on how to balance the demand for information with businesses compliance costs in order to achieve materiality. The same thinking should be applied to the identification, valuation and pricing of climate risks. Finance Norway will address the proposed simplification measures in due course. Financing of SME activity and ownership is dominated by home bias, and local savings banks play a crucial part in these activities. A diversification is, however, welcome in several dimensions: type of investment vehicle, duration, venture experience, regional and national diversification etc. Based on the principle of proportionality, voluntary reporting should be possible for these companies. However, in certain instances, risk sharing can be a valuable addition. Instruments like InvestEU can play a significant role in risk-sharing, particularly in the venture or seed stages of financing new enterprises. Securitisation and Risk Management Securitisation is a useful part of the risk management and funding toolbox in financial markets aimed at enabling hypothecation of risks to increase the efficiency in use of bank regulatory capital as well as a funding tool. It should not be seen as a replacement for efficient funding instruments that already operate fully functioning markets. Investment, Savings, and Pensions A robust investment and savings culture is crucial for the development of the internal market. The reform of the pensions system and the allocation of financial choices and choice of supplier to the individual customer has exposed them to investment choices and increased financial literacy. Individual choice has increased the competitive pressure on the supplier. The easy access to pension information has informed investment decisions for retail customers and incentivised savings in addition to the first and second pillar pensions. The taxation of these savings products is instrumental in incentivising saving. Modernisation and funding of pensions systems is a complex political task, that clearly belongs to the national domain.
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Meeting with Didier Millerot (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Bundesverband deutscher Banken e.V. and

16 Jan 2025 · Upcoming topics in sustainable finance

Meeting with Sebastian Tynkkynen (Member of the European Parliament) and Finanssiala ry - Finance Finland and Finance Denmark

25 Sept 2024 · Pohjoismaisten finanssialajärjestöjen tilaisuus

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and Finance Denmark and Finance Sweden

9 Apr 2024 · Priorities for next EU term; Future EU agenda in financial services.

Meeting with Rasmus Andresen (Member of the European Parliament)

26 Oct 2023 · socio-economic situation in Europe

Response to Open finance framework

23 Oct 2023

Please find Finance Norways feedback on the Commissions proposal for a regulation of Financial Data Access enclosed.
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Response to EMIR Targeted review

21 Mar 2023

See attatched file.
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Meeting with Karolin Braunsberger-Reinhold (Member of the European Parliament, Shadow rapporteur) and Finanssiala ry - Finance Finland and

22 Apr 2022 · AMLR

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness) and Finanssiala ry - Finance Finland and

9 Dec 2021 · Basel III

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Finance Norway supports the European Union’s ambition to boost private and public sustainable investments and reduce the risk of “greenwashing”, and we appreciate the opportunity to comment on the draft delegated acts and how these may impact the Norwegian economy and industries. Although we are very supportive of the taxonomy, the generally strict stance of the Commission may slow the much needed and desired path toward greening of the economy. A somewhat more flexible and stepwise approach may well present a more efficient route. This is particularly true for many sectors and industries that have started on a transition path toward a sustainable future, many coming from a high emission starting point, but that will need more investments and correct incentives to reach their goals. Activities not yet defined by the taxonomy In Norway, we fear that important industries and activities not yet included in the taxonomy, i.e. fisheries and aquaculture, could be negatively impacted. We thus stress the importance to define the criteria for sectors/activities not yet included in the delegated acts as soon as possible. Climate change mitigation Construction and real estate activities With regards to the acquisition and ownership of buildings, we would like to point out that EPC ratings is not a good proxy of energy efficiency across EU countries, as the EPC scales are not comparable. For residential buildings, we propose that the calculated performance of the building must be within the top 15% of the local existing stock in terms of operational Primary Energy Demand, as proposed in the final TEG recommendation from March 2020. For non-residential buildings, we believe it is important to harmonize the requirements for energy efficiency across borders and at the same time ensure a sufficient stringent criterion. Different proof of energy efficiency should be considered eligible, including sustainable building certifications (e.g. BREEAM and LEED) and EPC certificate class A and B – but only when it can be proven that these certifications are at a sufficient stringent level in terms of energy efficiency. Renovation of existing buildings is crucial for the transition of the building stock to become more energy efficient. With this in mind, we underline that when a renovation is compliant with requirements for major renovations according to the TSC for renovations the entire building should be eligible, not only the costs for the renovation. This should be irrespective of reached EPC class. With regards to the criteria for construction of new buildings we believe the use of the NZEB criteria could be challenging and lead to large differences in the thresholds across countries. We urge the Commission to find a solution that would harmonize the threshold across borders with respect to energy demand. Sea and coastal water freight transport Shipping and coastal supply services are important industries in Norway, and we have some concerns related to the criteria that the vessels cannot be dedicated to the transport of fossil fuels. We believe that the vessels should be assessed on their own performance and the level of greenhouse gas emissions instead of the nature of cargo. In addition, we believe that the criteria for hybrid vessels should be set at a threshold that is possible to reach also for long distance shipping. Electricity generation from hydropower We are concerned that the DA do not follow the technology neutrality principle and impose stricter criteria for hydropower than for other renewable energy sources. The same principles should be implemented for all renewable energy sources. Climate change adaption Non-Life Insurance The loss-data sharing criteria in the taxonomy has not defined the external parties which should get access to this data, the granularity of the data, how external parties should document the need for data and how privacy issues should be handled. We urge the Commission to address these questions.
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Meeting with Jyrki Katainen (Vice-President) and Finanssiala ry - Finance Finland and

14 May 2019 · Basel Implementation

Response to Legislative proposal for an EU framework on crowd and peer to peer finance

20 Nov 2017

Finance Norway welcomes the initiative from the EU Commission regarding a possible legislative proposal for an EU framework on crowd and peer to peer finance. Experience seems to tell us that crowdfunding has developed better in jurisdictions with a relevant and transparent regulation than in jurisdiction without such a framework. The objectives that has been set by the Commission for the possible legal proposal are important and relevant objectives. We think that the creation of a level playing field is important to enable platforms to scale cross-border. A proportionate and effective risk management framework is necessary to secure the reliability of and the trust in the platforms. It is also important that such a framework secures a level playing field for more traditional banks and investment firms competing with the platforms. It is Finance Norway’s opinion that only one of the four policy options would be able to fully deliver on the two objectives. Policy option number one (Baseline scenario – no EU framework) would only prolong a status quo situation. Policy option number two (Building on reputational capital - a self-regulatory approach with minimum EU standards) would be a move in the right direction, but it would not secure the reliability of platforms as the choice to operate below “best practise”-standards would be an option. Policy option number four (The cross-border solution - a standalone opt-in EU framework) would move the situation in the right direction and represent a noticable move forward. However, the fourth policy option does not secure a level playing field. National platforms could gain a regulatory advantage compared with cross-border platforms due to potential less demanding local regulations. Further, a lack of reliability in local platforms operating below “best practise”-standards could have negative contagion upon the trust in cross-border platforms. Thus, it is the opinion of Finance Norway that policy option number three (A comprehensive EU approach - treating crowdfunding platforms like regulated trading venues or payment institutions) represents the best solution. This is the only option that both secures a level playing field, enabling platforms to scale cross-border, and at the same time securing reliability and trust through a proportionate and effective risk management framework. However, under policy option four one must not only assess the regulations of regulated markets and payment institutions as the relevant alternatives. Existing regulations of credit institutions, credit intermediators and investment firms should be taken into account in order to reflect the nature of the platforms different services and nature. The Financial Supervisory Authority of Norway performed such a thorough assessment earlier this year, identifying different authorisations as relevant for different kinds of platforms. Finance Norway would like to highlight some core principles that such a legal framework needs to address: • The principle of “same risk – same activity – same regulation” must be the basis for the choice of regulatory approach, to secure a level playing field (a) between different platforms and (b) between platforms and more traditional banks / investment firms. • The regulatory framework must duly address the ICT risks and other operational risks, including AML risks, that such platforms represents. • The regulatory framework must duly address the need to secure the interests of investors and consumers, including the need to secure consumers against such platforms creating a too easy way of obtaining non-sustainable credit. • The regulations must also clearly make the platforms and the owners and operators of such platforms responsible for funds invested through their platform.
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